On May 9, MFA submitted a comment letter to FinCEN on its proposed amendments to the FBAR rules. The letter encourages FinCEN to: (1) clarify that officers and employees of registered advisers will not have FBAR filing obligations with respect to client accounts for which they only have signature authority; and (2) maintain the special reporting provisions for U.S. persons with 25 or more foreign financial accounts, at least for registered advisers that must file FBARs. The letter also suggests that if FinCEN decides to remove the special reporting provisions it should wait until there is greater certainty regarding the persons and entities required to file FBARs and consider amending the reporting form to reduce administrative burdens on filers by permitting them to submit information in a manner consistent with how firms maintain that information as part of their regular course of business.